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Off to the VOSH Conference

Wednesday, May 26th, 2010

Jan at last year’s VOSH Conference discussing the finer points of purchasing the correct electrical safety equipment. (Photo: from Virginia Department of Labor & Industry video of session and off of their website)

A little bragging here… The VOSH Conference has been growing every year since its inception 15 years ago. The idea for a professional gathering supported by Virginia Department of Labor and Industry was an idea that I suggested when I was the Chief Administrator of VOSH way back in the early 1980’s but it didn’t take off until 1995. By that time I was starting Circle Safety. I was honored to be an invited speaker at the first conference and have been invited back each year. That’s a lot of presentations.

This year I suggested speaking on how safety and health professionals can use Digital Photography in Support of Safety. Here is the brochure description:

This is not your typical accident investigation photography class. Instead, we will discuss the ever- growing opportunities to use – and misuse – digital photography in our safety and health efforts. Topics will include effective use of the camera as a tool in documentation of the workplace; camera selection (point & shoots are just fine); privacy and property rights, including legal and ethical issues; use of digital images for safety training and communication of safety messages; use of image- enhancing software. If you are reading this before the conference, you are invited to bring prints of your best examples of “digital safety.” We will set up an exhibit! All levels of photo experience are welcome – this is really about safety!

Those of you who have been following this blog will see my sneaky attempt to merge my professional work with my love of photography. If you are in the Northern Virginia – DC – Maryland region, please join us June 1 – 4, 2010. Day-tripper admissions are available. Follow the link above and bring your safety photos with you.

Tags: VOSH
Posted in All Industries, Safety Photography | No Comments »

First Impressions Really Are a First Clue

Wednesday, February 10th, 2010

Housekeeping not so good. And how many hazards can you find? (Photo: Jan Thomas)

You’re driving into the worksite, getting out of your vehicle and walking to the office. Maybe you are the insurance agent on an annual audit, or maybe the corporate safety director doing the rounds, or a third-party safety auditor. Or you’re the newest employee reporting for duty, or the OSHA officer entering the site. The general first impression of the facility or construction site or office complex or any other workplace really gives the first clue as to how safety is valued.

I’ve been saying this to clients for years. Get your housekeeping in order! Build good looking guards! Keep the PPE looking “sharp.” Make it look good and you will also make it safe! Don’t you think the next photo provides a better first impression?

This site was so well organized there were very few suggestions for improvements. (Photo: Jan Thomas)

Tags: Housekeeping
Posted in All Industries, Safety Advise | No Comments »

The Dreaded Portable Incandescent Hand Lamp

Monday, February 1st, 2010

Hand lamp being used as an extension cord at welding table in a heavy equipment repair shed open to the weather. (Photo: Jan Thomas)

I don’t like this type of portable lamp for several safety reasons. First, I’ve done one too many accident investigations that involved an incandescent bulb “trouble light.” The classic accident involves the mechanic that takes this lamp under the hood or under the equipment/vehicle and begins to work on the fuel system. Dripping fuel + hot electrical bulb = explosion & pain.

Aside from applicable OSHA standards we have support from Underwriters Laboratory which specifically states that “these products are not intended for outdoor use unless marked “Suitable for Wet Locations,” or for use in hazardous (classified) locations…” (UL 298, the Standard for Safety of Portable Electric Hand Lamps).The other reason for worrying about employee use is that the handle on many lamps provides a plug – supposedly for attachment of a small appliance like a shop radio or small bench tool – but which is misused in industrial and construction sites as an “extender” for extension cords (see above). The hand lamp is now susceptible to being dragged around on the floor or hitting metal.

And, as a special side note… I usually find misuse of this type of equipment paired with a lack of GFCI protection, thus doubling the risk.

The solution – purchase heavy duty portable lighting with proper bulb protection and NO outlet on the handle. Use GFCI!

Tags: GFCI, Hand Lamp Safety
Posted in All Industries, Consensus Standards | 1 Comment »

Photographs That Support Our Safety Message

Wednesday, January 13th, 2010

As per the eLCOSH Use Policy – this is a screenshot of the browse page at CPWR — The Center for Construction Research & Training, elcosh.org/images.

One of the difficulties faced by safety professionals is finding the right image to show during training and other times—whenever conveying a safety message to others. I’ve been consciously building a photo gallery of the “good, bad and the ugly” for over 30 years. My early OSHA compliance photos got left in the Federal files and anyway, they suffered from the media of their day (Kodak Instamatic or Polaroids).

When I switched to digital I began my current collection which now suffers from my lack of time to organize it and digitally enhance or correct some images. Even though I’ve got enough of my own shots to support this website (although I still waste time finding the right one) I’m always on the lookout for others’ helpful collections. Voila.

Just this month The Center for Construction Research and Training (eLCOSH) added a free-of-charge image library to their already helpful website. It provides high resolution, downloadable photos of hazards on construction sites. Each photo has been fully described and the site is well organized and searchable by key words. Find it at www.elcoshimages.org.

Be sure to read the “Use Policy” before you download. Thanks, eLCOSH, and thanks to all the contributing photographers.

Tags: Safety Photography
Posted in All Industries, Construction | No Comments »

Low Bid = High Risk?

Wednesday, January 6th, 2010

Forty feet up or more. (All photos by Jan Thomas)

I’ve dipped into my photo collection to start out this year’s blogging. It’s been several years since I took this series of pictures from a public street near Circle Safety’s Richmond offices.

Look closely… Two guys, on an aluminum work board (not a two-point suspended scaffold), one with a hard hat and PFAS in use, the other getting a good suntan. The horizontal white lines you see are ropes strung through small diameter PVC pipe, one on each side of the work board. Acting or at least looking like guardrails? Look closer and you’ll see more problems.

The biggest problem could be missed but I believe is the root cause of the observed hazards – these guys are working for the company that won the low bid to do cleaning and painting of this tower. I don’t know for sure but I’ll bet they were required to provide their own equipment.

I want to say right now that although I do have my “hazard radar” turned on almost all the time, I very rarely make a referral of an unsafe condition to OSHA. It has to be a true imminent danger situation which I believed this to be.

(In a later blog I would like to speak to the issue of a “duty to respond.” I have spoken with many professions including enforcement officers, emergency responders and public officials who have admitted to the dilemma of not always knowing if they should ignore something or get involved.)

It wasn’t my jobsite or my client, but on this day I decided that I had to save two lives. I took the photos and contacted my local VOSH office. Within half an hour, these lucky workers were on the ground talking to a VOSH inspector.

Rock climbing equipment attached to wire rope….

I say “lucky” because the photo below is a close-up of their sole anchor point.

What do you think?

Tags: Incorrect Suspended Scaffold, Unsafe PFAS
Posted in All Industries, Construction, General Industry | 1 Comment »

That Old Hard Hat Rule & A Few Exceptions

Monday, December 14th, 2009

Trim carpenter set up to work by himself with his hard hat parked at the door. Hmm… Please don’t hang your hat on the switch wiring even though it’s not hot, and don’t run your cord across the metal door frame unless you protect it. (Photo: Jan Thomas)

I keep a list of what I call “challenge questions.” When I’m looking for a blog topic I can always find inspiration as well as frustration by looking at my list. When I’m walking a construction site and encounter crews who have not worked with me before—and don’t already know my response, I’m often asked one of these questions.

Here is an example: “So, I’ve always been told I don’t have to wear a hard hat if no one is working around me. Why are you telling me different now?”

Those of you who have been reading my blog know my bottom-line answer to this and similar questions is – “Our company/site policy goes beyond OSHA standards. In this case, our policy is to wear hard hats 100% of the time with only a few exceptions.” It’s the part about “a few exceptions” that leads to long discussions, which I try to use as “teaching moments.”

I start by acknowledging that the main OSHA hard hat requirements are found in two places – General Industry’s §1910.135 & Construction’s §1926.100. Both require employers to determine the need for PPE and sometimes this leads to the evaluation that there is no possible danger if a person is working alone, or in the cab of a well-protected piece of equipment, or under a cabinet fitting a fixture. And, yes, OSHA said in 1983 that “where employees are not exposed to possible head injuries, head protection is not required by OSHA standards.”

Yet, typical hazards are not always anticipated, such as the hot electrical connection not seen yet touched by the worker’s head, or the rock that ricochets into the open window of the excavator’s cab, or the worker’s own dry wall hammer bouncing off a stud into his forehead. Ouch.

Believe me, I’ve seen all of these happen more than once. That’s why I try to convince my clients and all I contact in workplaces to wear their hardhats all the time (okay, except for maybe when they are sitting in the lunch trailer or in their car taking a nap).

Tags: Hard Hat, OSHA, PPE
Posted in All Industries, Construction, General Industry | No Comments »

Workplace Violence Trends in Virginia

Thursday, December 3rd, 2009

Some of the Workplace Violence resources I have collected through the years. (Photo: Jan Thomas) Earlier this week I conducted a three-hour training session on workplace violence for local businesses. It was a good chance for me to review the very latest facts on this widely acknowledged employment issue.

Workplace violence was first studied by NIOSH and then OSHA in the late 1980’s. Issues and characteristics as well as preventions and controls were researched and promoted, and then the topic faded from the public’s radar although it continued to be of interest to data collectors, if not safety and human resource managers. Since I was one of the first people to research this issue in Virginia (during my university professor days), I have also been quietly monitoring the ups and downs of this subject in the Commonwealth and I’m getting more concerned.

Take a look and decide for yourself. The easiest place to start is at the Bureau of Labor Statistics (BLS) and their Injuries, Illnesses, and Fatalities Report (IIF). Workplace homicides have declined more than 50 percent since 1994 but the most recent IIF report offers preliminary data for 2008 and shows 37 fatalities coded as workplace violence in Virginia! This appears high and well above the national average of 10-12 per state.

The most recent, fully investigated year of BLS data is for 2007—the year of the Virginia Tech massacre. In 2007, there were 21 workplace violence fatalities. Included in this year’s data were five of the 32 deaths at Virginia Tech. These five were faculty/employees and were counted by BLS. Yet, despite Virginia Tech being the deadliest of public shootings in Virginia (as well as in the United States) its number of workers dead is less than a quarter of those who died by violence in Virginia workplaces in 2007.

In 2006, there were 32 cases of workplace violence in Virginia. Put these 3 data points together – 2006 (32 cases), 2007 (21 cases), 2008 (37 cases) and while we don’t necessarily see an increasingly upward trend, we do notice a tendency toward large numbers. Workplace violence and some of its precursors – highly stressed individuals are still present and may be growing, due to the hard economic times and the tension of possible layoffs.

It’s a good time to dust off the workplace violence policies and revamp them for current issues and modern technology. More on this topic later.

Tags: Workplace Violence
Posted in All Industries, Safety Topics | No Comments »

Looking a Little Closer at Laser Safety

Monday, November 23rd, 2009

Laser warning sign, laser safety glasses and safety instructions – all rare sights in the workplace. (Photo: Jan Thomas)

Lasers are taking over! They are incorporated into kid and pet toys and will probably be a very popular holiday season gift for the DIY tool collector. Their presence in the industrial and construction worksites has been growing too. But, I believe workplace safety awareness has actually decreased as laser use has become more common place.

Lasers used to be a rare sight on construction sites. When they were used, a warning sign was often posted. The user was sometimes “certified” by the manufacturer. Other workers stayed out of the posted area. The laser safety glasses were in the carrying case although hardly ever used. And, no one really knew much about the potential dangers other than “you shouldn’t look into the beam.”

Most of these conditions have remained the same except that I now see more lasers in use, no warning signs, and a lack of training or qualification to use. But, the OSHA laser standard remains the same and requires all of this – see 29 CFR 1926.54.

Typical leveling lasers seen on construction sites today are rated at less than 1mW and therefore fall into a Class II category as per the Laser Hazards- Section III: Chapter 6 of the OSHA Technical Manual.

Quoting from it “CLASS II: low power visible lasers which emit above Class I levels but emitting a radiant power not above 1 mW. The concept is that the human aversion reaction to bright light will protect a person.” The referenced “human aversion reaction” is a fancy way to say “eye blinking.”

So, bottom line…. We want the laser operator trained with documentation. The user is to post a notice telling us what Class laser is in use. All employees in the area need laser safety awareness training. And, what about those weird red glasses? If the equipment is Class III or IV then we will probably need special laser eye protection depending upon the exposure. BUT, if it is Class I or II – everyday construction laser – then all we need to do is be aware a laser is in use and not try to out stare it.

By the way, I’ve not referenced OSHA’s Technical Manual on this blog before – it’s the official go-to guide for the OSHA compliance officers and therefore is of use to us.

Tags: Construction Safety, Laser Safety, OSHA
Posted in All Industries, Construction, General Industry, Safety Advise | No Comments »

Tying off on Scissor Lifts in Virginia

Monday, November 16th, 2009

Only one of several types of tie-off instructions put on modern scissor lifts. (Photo: Jan Thomas)

Last Friday I received a call from a client’s superintendent asking me to go over the reasoning and authority for tying off on scissor lift and other personnel hoists. This is the same question I’ve been answering for years and I’ve been answering it in the same way for years… specifically, “Despite what OSHA says, if the manufacturer has provided anchors points, please use them as they have been put there for your safety!”

In Virginia, in the fall of 2006, my answer became a little stronger as I could now point to the “authority” of VOSH when someone wanted to argue with me that OSHA doesn’t require tie off on scissor lifts.

Earlier this year I wrote our clients a memo on this topic – it applies to industrial worksites, construction and all sectors of employment in between. Here is a link to that memo.

By the way, the superintendent was being questioned by one of his disbelieving subs. So I reminded him that the true answer to “Why do we have to tie-off?” is “Because it’s our rule!”

Tags: ANSI, Construction Safety, Fall protection, Industrial Safety, OSHA, Personnel Hoists, Scissor Lifts, VOSH
Posted in All Industries | No Comments »

Ban the Wire!

Tuesday, October 20th, 2009

Good example of “gambling with wire” while stringing up temporary lights (Photo: Jan Thomas).

While teaching electrical safety in our OSHA 10/30 classes I like to throw out the question “Who thinks putting metal and potentially exposed electrical together is a good idea?” On all worksites I’ve seen a slow evolution to the use of nonconductive tools and equipment. For example, the replacement of metal ladders for fiberglass, the repair of extension cords with molded plastic replacement plugs, the use of plastic cages on temporary light strings instead of metal guards. All good, but in today’s photo we have short lengths of wire being used to hang the sting lights.

Is this a problem? The string lights are from a reputable manufacturer. Built-in molded plastic hanger eyes are provided. But, check the manufacturers’ literature- the plastic hanger eye is provided for use with “messenger cable or hooks.” Messenger cable??? Why bother with that when we can just hang the lamps using some bits of wire?

Look closely – this is not a usual case – the lamp assembly is pulled over and tied off to a metal stud with a spare length of wire pointing into the aisle, ready to catch a worker or hit the bulb. Then there is a small twist of wire being used to lock the clam shell type cage. Why is wire being used when plastic zip ties and bits of string are readily available in the workplace?

The installation shown above might pass OSHA inspection since the wire is passing through the manufacturer’s establish plastic eye (reference OSHA 1926.405(a)(2)(ii)(F) Temporary lights shall not be suspended by their electric cords unless cords and light are designed for this means of suspension).

My suggestions – stop arguing about OSHA compliance. Instead, fool proof everyone’s safety by setting up a worksite rule that says “ NO wires” when setting up temporary lighting or extension cords, that keeps everyone from making a random mistake that could lead to electrical shock.

Tags: Electrical Safety, OSHA, Safety Management
Posted in All Industries, Construction, Safety Advise, Safety Topics | 1 Comment »